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Genentech Fully Supports Efforts to Increase Transparency

Genentech fully supports efforts to increase transparency around the
partnership between the industry and healthcare professionals.

We believe the partnership between the medical community and companies like
ours who discover and develop medicines is critically important to our shared goals of
advancing scientific knowledge and delivering new medicines to patients in need.

Our ability to engage with doctors, researchers and opinion leaders in robust
dialogue on approved and investigational medicines is vital to our research and development
efforts. These external experts also lead the clinical trials evaluating the safety and
efficacy of our medicines, and provide critical information and insight into patient
needs.

Sunshine Act Compliance

The Sunshine Act, a.k.a. the National Physician Payment Transparency Program (Open Payments),
is a section of the Patient Protection and Affordable Care Act of 2010. It requires
pharmaceutical and medical device companies report certain payments to the Federal
government.

Genentech is committed to ensuring that the Sunshine Act data we report is as accurate as
possible, and we employed extensive processes to collect and review the data prior to
submission.

We are also committed to providing healthcare professionals with the information they need to
accurately track their Sunshine-reportable payments. To help in this effort, we have
developed a secure online tool called Sunshine Track.

Want to see it in Action?

Our Sunshine Track® Tool

Sunshine Track is a secure online portal that will allow you to review your
Sunshine-reportable payments before they are reported to the government.

With a click or tap, Sunshine Track allows you to inquire about or dispute any
Sunshine-reportable information that you think may be inaccurate.

Note: Sunshine Track is not supported by Internet Explorer 8 or earlier.

Welcome to Genentech’s Sunshine Track

This user guide describes the features and functionality in the Sunshine Track
tool. To get started, choose a topic below.

OverviewApplication Layout

Header

Provides access to search, contact and links about
Genentech.

Payment List

A list of reportable payments.

Professional Information

Information about your Genentech account. Also provides
access to Account and Settings functionality.

Filters

Displays editable criteria to assist you in finding
payments.

Footer

Always anchored at the bottom, the footer provides access to
help, FAQ and legal content. The footer can be expanded to
access more Genentech content.

Header

Payment List

Filters

Footer

Header

Search

Search the Genentech website. Note: This search will not
search payments in Sunshine Track.

Contact

Use this to contact the Genentech Sunshine Track support team
or Genentech corporate offices for general inquiries.

About Us

Displays content and links about Genentech.

Footer

Help

Opens this tutorial.

Log Out

Terminates the current user session.

Expanding Footer

Reveals information and links about Genentech.

Filters

Display payments based on date, amount, payment method and more.Display payments based on date, amount, payment method and more.

Select the "Filter Icon" to display the Filter list.

Payment List

Shows a list of reportable transfers of value
Genentech attributes to you including meals or travel related
expenses. If you are a principal investigator of a research study
you will have access to an additional payment list that displays
research payments only.

Filter Payments

New/Recently Updated

A toggle-able filter that displays only new or updated
payments (since the last login) that also match the active
combination of filters. Note: Selection of this filter
removes the "Bookmarked" filter.

Bookmarked

When selected, this filter displays only bookmarked payments
that have been previously bookmarked. Note: this filter
clears the "New / Recently Updated Filter".

Clear All

Removes all active filters.

Filter Payments

Filter by Date

An editable filter for viewing payments by date range or date
period.

Filter by Amount

An editable filter for viewing payments over a certain amount
or within a range.

The Payment List

Payments related to research will be
displayed in a separate "research payment" list.

Research Payments will display fewer
filtering options.

Sorting and Exporting

Filtered Payments Count and Total Payment Count

Displays the number of payments matching the active
combination of filters and the total number of payments.

Sortable Column Headers

In the payment list, the most recent payments are shown
first. Choose a column header to change the order payments
are displayed. Choose once to make the column active, choose
again to reverse the order or the sort.

Export

You may export your full list of payments by choosing the
"Export" button. You may export as a CSV or PDF.

Quick View

Quickly view details and take action on
the selected payment. If the payment has been disputed, a Dispute
History will be shown.

Detail View Button

Provides further details about the payment.

Dispute Button

Dispute this payment.

Bookmark Button

Bookmark this payment for easier reference.

Note for principal investigators:

Data displayed for a research payments will differ however, the
options to dispute, bookmark and view details are available.

Detail View

Reportable Information

Payment data that will be reported to the government.

Related Information

Non-reportable payment information that helps recall the
payment.

Disputed Payments

Disputed payments will display tabs that include dispute
history and a send a message tool.

Disputing a Payment

Payments can be disputed for many reasons.
Therefore, the dispute overlay allows for input of free-form
comments and the ability to dispute and/or suggest values at the
payment attribute level. Once disputed, the payment will be marked
with a Payment Status of "In Progress". Payment disputes that are
resolved are shown with a Payment Status of "Resolved".

Viewing Disputed Payment Information

Payment Details

Displays the disputed information - including any information
you provided when submitting the dispute.

History

A summary of activity associated with the resolution of a
disputed payment.

Send a Message

You may send a message to the Genentech Sunshine Track Team
regarding a disputed payment at any time if you have any
information to add.

Payment Statuses

In Progress

The payment is currently under review and any activity will
be sent to you based on your preferred communication
method.

Resolved

Dispute information for the payment has been investigated and
Genentech has reached a resolution.

Reportable period start date

CMS issued the Sunshine Act final rule on February 1, 2013, and
established August 1, 2013 as the start date for data
collection.

Report due to government

Genentech reports the data annually to CMS on March 31.

Government Publication Date

CMS will publish the data publicly by June 30.

Required Reporting Entities

APPLICABLE GROUP PURCHASING ORGANIZATION

The term 'applicable group purchasing organization' means a
group purchasing organization (as defined by the Secretary)
that purchases, arranges for, or negotiates the purchase of
a covered drug, device, biological, or medical supply which
is operating in the United States, or in a territory,
possession, or commonwealth of the United States.

APPLICABLE MANUFACTURER

The term 'applicable manufacturer' means a manufacturer of a
covered drug, device, biological, or medical supply which is
operating in the United States, or in a territory,
possession, or commonwealth of the United States.

Definition of Covered Products

COVERED DEVICE

The term 'covered device' means any device for which payment
is available under title XVIII or a State plan under title
XIX or XXI (or a waiver of such a plan).

COVERED DRUG, DEVICE, BIOLOGICAL, OR MEDICAL SUPPLY

The term 'covered drug, device, biological, or medical
supply' means any drug, biological product, device, or
medical supply for which payment is available under title
XVIII or a State plan under title XIX or XXI (or a waiver of
such a plan)

Information Requirements in the Disclosure

Name

Business address

Physician specialty

National provider identifier

The value of the transfer or payment

The Brand/scientific name of the associated drug or
device

Form of payment

Cash or cash equivalent

In-kind items or services

Stock, a stock option, or any other ownership
interest, dividend, profit or other return on
investment

Nature of Payment

Entity or individual that received payment at the
request of or designated on behalf of covered recipient

Specific Payment Types Which Must be Reported

consulting fees

compensation for services other than consulting

honoraria

gift

entertainment

Travel and lodging (including the specified
destinations)

food & beverage

education

research

charitable contribution

royalty or license

current or prospective ownership or investment
interest

direct compensation for serving as faculty or as a
speaker for a medical education program

grant

Space rental or facility fees (when paid to a teaching
hospital)

Covered People and Entities

Physicians

Teaching hospitals

Excluded from Reporting

A transfer of anything of value which is less than $10,
unless the aggregate amount transferred to, requested by, or
designated on behalf of the covered recipient by the
applicable manufacturer during the calendar year exceeds
$100.

Product samples that are not intended to be sold and are
intended for patient use

Educational materials that directly benefit patients or
are intended for patient use

The loan of a covered device for a short-term trial
period, not to exceed 90 days, to permit evaluation of
the covered device by the covered recipient

Items or services provided under a contractual
warranty

A transfer of anything of value to a covered recipient
when the covered recipient is a patient

Discounts (including rebates)

In-kind items used for the provision of charity care

A dividend or other profit distribution from, or
ownership or investment interest in, a publicly traded
security and mutual fund

In the case of an applicable manufacturer who offers a
self-insured plan, payments for the provision of health
care to employees under the plan

If the transfer is payment solely for the non-medical
professional services

If the transfer is payment solely for the services of
the covered recipient with respect to a civil or
criminal action or an administrative proceeding

Clinical Development Investigations

Reportable, but not required to publicly disclose until
either:

FDA approval date or

Four calendar years after payment date

Penalties

Failure to report subject to a penalty of not less than
$1,000, but not more than $10,000 for each payment or other
transfer of value not reported.

The total civil penalty will not exceed $150,000 per
calendar year.

Knowingly failing to submit payment data results in a
penalty of not less than $10,000, but not more than
$100,000, for each payment.

Penalty will not exceed $1,000,000 per calendar year.

State law preemption

All state laws that impose the same reporting requirements
are pre-empted by this law.

State laws that impose different reporting or prohibition
provisions shall continue to be effective.